PUBLIC COMMENT – DEMOLITION WORK CODE OF PRACTICE
FROM: VICTORIAN CONSTRUCTION SAFETY ALLIANCE
RELEVANT SECTION OF COP
1.1 What is demolition work
1.3
What is involved in managing the
risks of demolition work
ISSUE
The VCSA recommend that the definition of demolition work be
expanded to incorporate soft demolition works i.e. internal strip
out tasks. There are many high risks associated with soft
demolition, for example, unidentified asbestos that is commonly
found in lagging behind cavities, walls and other hard to access
areas. The asbestos, in these instances are rarely identified in
hazardous materials audits. Another high risk area of soft
demolition is exposure to live services.
Not including soft demolition in the definition of demolition
services and thereby the requirement to hold a license could
result in unlicensed, inexperienced operators being put at a
higher risk of injury.
Page 6 – Consulting with Workers states that “If the workers are
represented by a health and safety representative, the
consultation must involve that representative”. In some
instances this mandatory consultation will not be practicable or
possible.
RELATED LEGISLATION / CODES
Model WHS Regs section 70
All other COP’s
In additional the Model WHS Regs states at section 70 that the
obligations to consult with the HSR is to “consult, so far as is
reasonably practicable….” The VCSA strongly recommends that
the code accurately reflect the Regs by including “so far as is
reasonably practicable”.
2.3
Controlling the risks
Page 8 - Reference to the “hierarchy of risk control”. This has
been internationally referred to as the “Hierarchy of Control” for
many years and this reference throughout this code of practice is
also inconsistent with section 36 of the Model WHS Regs which
states “Hierarchy of Control Measures”.
Model WHS Regs Section 36
The VCSA do not support the sudden change in terminology as
we believe that it may unnecessarily confuse workers and the
Page 1 of 4
PUBLIC COMMENT – DEMOLITION WORK CODE OF PRACTICE
FROM: VICTORIAN CONSTRUCTION SAFETY ALLIANCE
RELEVANT SECTION OF COP
ISSUE
change does not add value given that it already a well
understood term.
RELATED LEGISLATION / CODES
The VCSA are of the view that the way the Hierarchy ranking as
explained is not clear enough. The VCSA recommends
That the Hierarchy of Control be explained simply and concisely
as follows:
The following options to eliminate or reduce the risk must be
used in descending order:
1. Elimination the hazard
2. Substitute the hazard with a safer option
3. Isolate the hazard from people
4. Reduce the risks through engineering controls
5. Reduce exposure to hazard using administrative controls
6. Use Personal Protective Equipment
3.4
Preparing safe work method
statements
4.3
Induced Collapse – Wire Rope,
slings and chain pulling
6.4
Plant and equipment
This section states that one SWMS can be prepared to cover all
high risk construction work being carried out.
Given the high risk and detailed nature of the tasks within a
demolition project the VCSA recommends that this approach
would not always be practicable as the resultant SWMS would be
very long and could potentially confuse the worker as not all
tasks would relate to them. The VCSA recommends that this
statement be removed.
The VCSA recommends that this section be referenced back to
the hierarchy of control as this method should only be used as a
last resort. Other methods, higher up on the hierarchy of control,
should be considered first and only when not practicable should
this method be used.
The VCSA recommends that this section be used as an
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PUBLIC COMMENT – DEMOLITION WORK CODE OF PRACTICE
FROM: VICTORIAN CONSTRUCTION SAFETY ALLIANCE
RELEVANT SECTION OF COP
6.7
Fall prevention Devices
ISSUE
opportunity to provide further guidance on safe practices for the
use of both demo saws and Oxy-acetylene (gas cutting) in the
same manner as more information has been provided around
scaffolding and EWP’s.
RELATED LEGISLATION / CODES
These two work methods are used regularly in demolition works
and both potentially expose the worker to high risk situations if
not used properly. This document allows an excellent
opportunity to provide specific guidance for use.
“Fall prevention devices include perimeter guard rails, the
protection of openings and solid covers and temporary work
platforms.”
The VCSA recommends that this sentence include more
information to ensure that “solid covers”, used to cover
penetrations for example, are built to withstand the weight of
which it must hold i.e. workers or plant and equipment.
“All penetrations in floors, roofs or any other place where work
may be carried out should be protected either by covering them
with rigid and fixed material of sufficient strength to prevent any
persons or debris falling through…”
6.7
Elevated work platforms
The VCSA recommends that the above sentence be expanded to
include the possibility of Plant and equipment falling through.
Page 35
The VCSA recommends that the sentence that states that hot
works not be done from a boom be removed. In reality more hot
works are done from a boom type lift than a scissor lift. The
reason for this is that a boom allows for a drop zone below the
bucket during the demolition process whereas an EWP does not.
This makes the EWP a less safe option than the boom. The VCSA
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PUBLIC COMMENT – DEMOLITION WORK CODE OF PRACTICE
FROM: VICTORIAN CONSTRUCTION SAFETY ALLIANCE
RELEVANT SECTION OF COP
6.7
Work positioning systems & Fall
arrest systems
ISSUE
suggests that the boom is the safer option and that when the
boom is fitted with a fire extinguisher it would be an acceptable
method of demolition combined with hot works.
The VCSA strongly recommends that a section be added to both
areas explaining the importance of competent users and the
testing and inspection of equipment.
RELATED LEGISLATION / CODES
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